Section 148 notice invalid for reassessment initiated based on incriminating material

City Life Projects Pvt Ltd. Vs ITO (ITAT Delhi)

1. A search and seizure operation was conducted at the premises of S.K. Jain Group where from certain incriminating material in the form of register and diaries were seized.

2. On the basis of seized documents, information was transmitted to the Assessing Officer of the assessee stating that the assessee has taken Hawala entry from S.K. Jain Group amounting to ₹ 10 lakhs.

3. On the basis of such information, notice u/s 148 of the Act was issued on the assessee

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